It has become commonplace to note the ascendancy in white-collar investigations of techniques previously reserved for investigations of organized crime and violent, life-and-death offenses. Three recent articles bring the issue around again. The New York Times notes that More Federal Agencies Are Using Undercover Operations: The federal government has significantly expanded undercover operations in recent years, with officers from at least 40 agencies posing as business people, welfare recipients, political protesters and even doctors or ministers to ferret out wrongdoing, records and interviews show. . . . Undercover work, inherently invasive and sometimes dangerous, was once largely the domain of the F.B.I. and a few other law enforcement agencies at the federal level.…

You use your cell phone for work? In a potentially important Title III opinion, the Fifth Circuit limits the territorial reach of cellphone interception in United States v. Richard North. In part: “[A] district court cannot authorize interception of cell phone calls when neither the phone nor the listening post is present within the court’s territorial jurisdiction.”